Compliance

Effective February 6, 2012, FINRA will migrate corporate and agency debt (Corporates and Agencies) trade reporting to a new technology platform. The new platform will conform only to the new trade data formats included in the CTCI and FIX protocols, and via the TRAQS secure website for Corporate and Agency Debt. This means that any transaction that was entered in the legacy TRACE (pre-February 6, 2012) Corporate and Agency system will not be available for cancellation or modification via the new formats. Firms instead must use the Reversal function to revise trades entered before February 6, 2012.

In preparation for the migration, FINRA recommends that firms download their legacy trade data at the end of each day leading up to the migration date. Firms can download their legacy trade data via the Trade Report Data function on the legacy TRACE website. The Trade Report Data function enables the reporting party or their Give-Up firms to search and view trades that have been previously accepted by TRACE.

Below are examples of the processes to revise trades once the migration is complete.

Function

Scenario—Trades entered prior to/on Feb 3, 2012

Scenario—Trades entered on/after Feb 6, 2012

Trade Cancel

Use Reversal function for any trade in TRACE

Use Cancel function up to T-20

Trade Correction

Use Reversal function for any trade in TRACE and re-enter trade as-of with an execution date of the original execution date

Use Correction function up to T-20 and re-enter trade as-of with an execution date of the original execution date

Trade Reversal

Apply in scenarios above

Use Reversal function after T-20

Trade Reversal action examples for trades entered before the migration is complete:

Users reversing legacy trades are required to submit an Original Control Date. (Firms should use the trade report date when the original trade was submitted in the legacy system, as the Original Control Date (conforming to the YYYYMMDD Control Date format).

Use the Reversal function. Side – BuyQuantity – 10000000.00 (par value dollar format)As-of – YOrig Control # – 2740000025Orig Control Date – 20101001* All other relevant trade details from original trade are required in the Reversal entry.